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foreign tax credit on tax paid for k-1 distributions?


cl2019

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taxpayer received 1065 k-1 distribution and paid tax to a foreign country. can he claim foreign tax credit for that payment? My first thought is that he can as although the distribution (if less than basis) is not taxable, the distribution is actually part of a pool of ordinary income plus contributions, etc. all of which have been taxed, so, he should be able to claim foreign tax credit to avoid double taxation.
Can anyone comment on this?
Thank you so much!

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